SERVICES PRIVACY POLICY Last Updated October 15, 2018

1. Introduction

Data privacy is important to Cintoo US, Inc. (“Cintoo”), its parent and all other companies of the Cintoo group (collectively “Cintoo Group” or “we” or “us” or “our”).

This Privacy Policy (“Privacy Policy”) provides information about our practices with respect to information, including Personal Information (as defined below) that we collect from you (“you” or “Customer(s)”) when you register to use and access the Cintoo’s services (available at https://cintoo.com/, the “Website”) (the “Services”), and that we process, on your behalf, from end-users when you grant them access to the Services (the “End-Users”).

This Privacy Policy also describes the choices available to you, regarding Cintoo’s use of your Personal Information, the steps you can take to access your Personal Information and to request, correct or delete it. Cintoo will not collect, use or disclose your Personal Information other than in compliance with this Privacy Policy.

Please note that for the purposes of the European Union’s General Data Protection Regulation (“GDPR”), Cintoo is the controller of Customer’s Personal Information and the processor of Service Data (as defined below) and the processor of End-User’ Personal Information.

By using and accessing our Services, you consent to the processing of Personal Information about you and your End-Users, and you signify that you agree to the terms of this Privacy Policy as well as to our Website Terms and Conditions of Use and Terms of Service.

If you have any question or concern regarding this Privacy Policy, please direct any inquiry to privacy@cintoo.com. or by mail to:

2.1 When this Privacy Policy applies: This Privacy Policy describes how Cintoo collects, processes and discloses your Personal Information when you and your End-Users use our Services. Any reference to “Personal Information” shall mean any information that can be used to uniquely identify or contact you or your End-User(s), as an individual, including but not limited to, your first and last name, email address, credentials, demographic data.

2.2 When this Privacy Policy does not apply: This Privacy Policy does not apply in the following situations:

Third-party websites: Our Website may contain links to third party websites that are not owned or controlled by Cintoo. This Privacy Policy does not apply to these third-party websites Please be aware that we are not responsible for the privacy practices of such other websites. We encourage you to read the privacy statements of each and every website that collects personal information.

End-Users: this Privacy Policy does not cover the collection and use of Personal Information by End Users. Customer shall be deemed to be the data controller of End-User’s Personal Information and Cintoo shall be deemed to be the data processor of such End-User’s Personal Information and shall process such information to enable End-Users to access and use the Services.

Visitors: this Privacy Policy does not cover the collection and use of Personal Information by Cintoo from individuals who visit our Website (the “Visitor(s)”). These privacy practices are detailed and governed by our separate Website Privacy Policy.

3. Table of Content

Personal Information collected through the Services

Personal Information that we automatically collect from you

Personal Information that we collect from other sources

How we use the Personal Information that we collect

How we share the Personal Information that we collect

International Transfers of Personal Information

How we store and secure the Personal Information we collect

How to access and control your Personal Information: your choices

Links to other websites

California Online Privacy Act

Children’s Personal Information

Updates to this Privacy Policy

Contact Us

4. Personal information collected through the Services

4.1 Personal Information Provided by Customers

4.1.1 Customer Account Registration

We collect and process your Personal Information when you register with Cintoo for an account or when you modify, edit your account. This Personal Information includes your first and last name, e-mail address, company name and company website address, job title, address, city, state, zip code and country, password and photo.

We use this information to process and fulfill your order, to enable you to access and use our Services.

4.1.2 Financial Information

Your financial information (credit card number, expiration date or other financial information) is used and stored by our payment processor (“Payment Processor”). We collect but do not store any financial information when you subscribe to our Services on our Website. Rather, all such information is transmitted directly via an encrypted connection (using secure socket layer (SSL) technology) to our Payment Processor. Currently we use Stripe as our Payment Processor, whose use and storage of your personal information is governed by Stripe’s own Privacy Policy.

We use this information to process and complete your subscription order and send you a transaction email confirmation.

4.1.3 Additional Information

You may also voluntarily disclose additional Personal Information when you contact our customer service for support, when you participate in a contest, promotion, survey, or when you opt in for direct marketing emails. We use this information to communicate with you via email and better understand your needs. However, please note that you will always be able to opt out of such direct marketing communications at any time (see below).

In all of the situations listed in Section 4.1 Cintoo processes Personal Information as a controller.

4.2 Personal Information we process on behalf of our Customers

4.2.1 End-User Personal Information

For all of the Personal Information we collect and process about End-Users through the Services, we act as a data processor on behalf of our Customers. We will only process such Personal Information on our Customer’s behalf and in accordance with their instructions (as defined in Terms of Service and its addenda, all together « Customer Agreement »). We have no direct relationship with End-Users whose Personal Information is processed in connection with our Customer’s use of our Services. If you are an End-User who interact with a Customer and would like to amend your contact information or no longer wish to use our Services, please contact the Customer directly, and not Cintoo.

Cintoo is not responsible for the privacy or security practices of our Customers, which may differ from those set forth in this Privacy Policy. If an End-User has questions or concerns about how such Personal Information is handled, the End-User should contact the Customer using the Services, and refer to their separate privacy policies.

We will process such End-User Personal Information to: provide and deliver the Services to the Customer and End-Users, prevent or address any service or technical issues, respond to a Customer’s request, instructions or support request, or for any other purpose provided for in our Customer Agreement, or in accordance with or as may be required by law.

4.2.2 Service Data

When you and your End-Users use our Services (including but not limited to when you upload, collaborate and share some files or other information, which may contain Personal Information (all together « Service Data »)), we will act as a data processor. We will only process such Personal Information on our Customer’s behalf and in accordance with their instructions (in the Customer Agreement.

We will use such Personal Information to: provide and deliver the Services to the Customer and End-Users, prevent or address any service or technical issues, respond to a Customer’s request, instructions or support request, or for any other purpose provided for in our Customer Agreement, or in accordance with or as may be required by law.

In such cases, it is the Customer who remain responsible for the handling of the Personal Information and with compliance with any applicable data privacy laws. If you have questions or concerns about how such Personal Information is handled, you should contact the Customer using the Services and bound by the Customer Agreement, and refer to their separate privacy policies.

5. Information we automatically collect and Why?

5.1 Information collected through Tracking Technologies

When you browse our Website, we may automatically collect certain information regarding your use of our Services (“Usage Information”).

Usage Information may include your internet protocol (IP) address, your browser type and operating system, device type, other unique identifiers (including mobile device identification numbers), Websites you visited before and after visiting our Website, pages you view and links you click on while using our Website, information collected through cookies and other tracking technologies, information about your interactions with e-mail messages, log files, and any other information about how you interacted with our Website.

We may collect this information to analyze your online activities on our Website and across third-party websites, to recognize you when you return on our Website, to store information about your preferences and to send you advertising and marketing emails. As provided below, you may opt out at any time of such advertising and marketing emails.

The technologies we use for Usage Information collection may include the following:

Cookies: Cookies are small information text files that are stored on your computer hard drive by your web browser when you use our Website. Cookies help us recognize you when you return to our Website. We also use cookies to ensure you obtain the information you request, to improve our Website navigation according to your needs and to understand your interests.

Strictly Necessary Cookies: Cintoo may use some strictly necessary cookies necessary to enable you to use our Website and some of its features, such as the language you choose while visiting our Website, or to track your cookies consent. Because these cookies are necessary to deliver the Website, you cannot refuse them. You can always block or delete them by changing your browser settings. However, some of our features on our Website may not function properly if you disable such cookies.

Performance and Functionality cookies: Cintoo may use performance and functionality cookies to collect information about how a Customer or End-User may use our Website, for instance, which pages you visit most often, or if you get an error message from a web page. These cookies don’t collect personal information. However, without such cookies, certain functionalities of our Website may become unavailable.

Analytics cookies: Cintoo may use analytics cookies to help us understand how our Website is being used and how effective our marketing strategy is, or to help us customize our Website for you. We use Google Analytics to analyze the use of our website. Google Analytics gathers information about website use by means of cookies.

Managing Cookies. You have the right to decide whether to accept or reject cookies. You can exercise your cookie preferences by clicking on the appropriate op-out links. If you have any questions regarding your cookie’s preferences, please direct any inquiry to cintoo@privacy.com.

5.2 Analytics Tools

We use Google Analytics to analyze information about your use of our Website. This service helps us to measure web traffic and to improve the effectiveness of our Website. The information gathered relating to our Website is used to create reports about the use of our Website. By using our Website, you allow Google to retain and use the information collected about you in your use of Google Analytics, subject to the terms of Google’s privacy policy available at: https://www.google.com/policies/privacy/.

5.3 Do not Track (“DNT”) signals

California law requires that operators of website and online services disclose how they respond to a Do Not Track signal and whether other third parties may collect personal information about an individual’s online activities from their Website or service. Some browsers have incorporated “Do Not Track” features. Most of these features, when turned on, send a signal or preference to the website or online service that a user visits, indicating that the user does not wish to be tracked. At this time, Cintoo does not currently respond to Do Not Track signal. We continue to work with the online industry to define a common understanding of how to treat Do Not Track signals.

6. Information we collect from other sources

We may also obtain information about you from other sources or retain third party services to operate our Website and help us monitor, collect, analyze and better understand your interactions with our Website. These other sources may include, without limitation, advertising services technologies and third-party advertisers, sponsor links on other third-party websites, database management, web analytics services.

7. How we use the information we collect

7.1 General Uses

We use your information, including Personal Information we collect about you for the following, but not limited, purposes:

To provide, operate, maintain improve and promote our Services;

To enable you to access and use our Services;

To send you technical notices, updates, support and administrative messages;

To communicate with you and respond to any Customer’s query or request you have submitted;

To send you information you have requested from us;

To send you information for marketing purposes and keep you posted on our latest product announcements, and upcoming promotional events (for opt-out instructions, see below);

To respond to you about any inquiry you have submitted;

To provide customer service and support;

To compile aggregated statistics about the operations and use of the Services and to better understand the preferences of our Customers;

To prevent or act against activities that are, or may be, in breach of our Privacy Policy or any other applicable law.

To alert you about a security announcement;

To carry out other legitimate purposes for which we obtain your consent.

7.2 Legal basis (for EEA Customers only)

If you are from the European Economic Area (“EEA”), our legal basis for collecting and using the Personal Information described above will depend on the Personal Information concerned and the specific context in which we collect it.

However, we will normally collect Personal Information from Customers only where we have Customers’ consent to do so, where we need the Personal Information to perform a contract with you, where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms, or where we have your consent. In some cases, we may also have a legal obligation to collect personal information from you.

If we ask a Customer to provide Personal Information to comply with a legal requirement or to perform a contract, we will make this clear at the relevant time and advise Customers whether the provision of Customers’ Personal Information is mandatory or not (as well as of the possible consequences if Customers do not provide their Personal Information).

Similarly, if we collect and use Customers’ Personal Information in reliance on our legitimate interests (or those of any third party), we will make clear to any Customer at the relevant time why we need to that Customer’s Personal Information. If we process Personal Information in reliance on Customers’ consent, Customers may be able to withdraw their consent at any time.

If you have questions about or need further information concerning the legal basis on which we collect and use Customer’s Personal Information, please contact us using the contact details provided under the “Contact Us” section below.

8.How we share the information we collect

8.1 We may share your Information with our Service Providers.

We employ and contract with people and other entities that provide us with certain services, such as hosting, maintenance and security of our Website, analytics (collectively, our “Service Providers”) to assist in the provision of our Website and Services. We provide these Service Providers with only the Personal Information they need to perform their services and work closely with them to ensure that your privacy is respected and protected. Unless we tell you differently, our Service Providers do not have any right to use Personal Information or other information we share with them beyond what is necessary to assist us. You hereby consent to our sharing of Personal Information with our Service Providers.

8.2 We may share your information in the event of a change of control.

We may also transfer and assign your Information in the event we are sold, acquired, or a majority of our business is acquired by a third party.

8.3 We may share your information with our related companies.

We may also share your Information with our related companies for purposes consistent with this Privacy Policy.

8.4 For Collaboration.

You can create, upload and share content, which may contain Personal Information. When you use certain features in the Services, you may share certain Personal Information with other End Users. For example, when you make some annotations on a project shared by multiple parties, you will share your first and last names with others.

8.5 We may share your information in response to legal requests.

We reserve the right to disclose information you provide to us as required by law, in response to legal process and law enforcement requests and as necessary or appropriate, in our view, to operate the Website, process registrations and to protect the rights or property of Cintoo (including but not limited to disclosure where we believe that such disclosure would be necessary or appropriate to investigate and defend ourselves against any third-party claims or allegations) or to protect the rights, safety or property of our Customers or others.

9. International Transfers of Personal Information

Cintoo may transfer your Personal Information between the Cintoo Group and/or to the third parties’ providers discussed above. We may transfer your Personal Information outside the EEA relying on appropriate or suitable safeguards or specific derogations recognized under data protection laws, including the GDPR.

The European Commission has adopted standard data protection clauses, which provide safeguards for Personal Information transferred outside of the EEA. We may use Standard Contractual Clauses when transferring Personal Information from a country in the EEA to a country outside the EEA. If your Personal Information are affected, you can request a copy of our Standard Contractual Clauses by contacting us as set forth in the Contact Us section below.

10. Security and Protection of Information

10.1 Security

Cintoo is committed to ensuring the security of your Personal Information. We take reasonable precautions to protect the confidentiality and security of your Personal Information placed on our Website. Any Personal Information that we store is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such systems and are required to keep the information confidential. In addition, all sensitive information you supply is encrypted via Secure Socket Layer (SSL) technology.

You may access your account information and our Services through the use of a password. To protect the confidentiality of Personal Information, you must keep your password confidential and not disclose it to any other person. Please advise us immediately if you believe your password has been misused. In addition, always logout and close your browser when you finish your session. If you have any questions about the security of your Personal Information, you can contact us at privacy@cintoo.com. We strive to take reasonable measure to protect your security. However, no security system is impenetrable we cannot guarantee that any information may be accessed, disclosed, altered or destroyed by any breach. For more details, please read our Security Policy.

10.2 Personal Information Retention

We will retain the Personal Information we collect where we have an ongoing legitimate business need to do so or until delete your account, whichever comes first. This is a case-by-case determination that depends on the nature of the date, why it is collected.

When you delete your account or when we have no ongoing legitimate business need to process your Personal Information, we will either delete it or anonymize it.

For example, where we are processing Personal Information based on your consent, that you voluntarily submitted to us, we generally will retain the Personal Information for the period of time necessary to carry out the processing activities to which you have consented (subject to your right, under certain circumstances to erase some of your Personal Information, see below Section 11).

11. Your choices

11.1 Promotional and Newsletter Communications.

You may opt out of receiving promotional and newsletter marketing emails by following the opt-out instructions provided in the bottom of those emails. We will process your request within a reasonable time after receipt. You will continue to receive transaction-related emails regarding products or services you have requested and administrative communications, such as updates to this Privacy Policy.

11.2 Accessing, Correcting or Editing your Personal Information.

You may update, correct or editing Personal Information associated with your account by contacting us by email at privacy@cintoo.com. Updates, corrections and edits will be approved within a reasonable time after receipt.

11.3 Deleting your Personal Information.

You may delete your account at any time by contacting us by email at privacy@cintoo.com. Deletion will be approved within a reasonable time after receipt, and we will not retain any Personal Information after deletion, except the retention of certain information as required by law or for legitimate business purposes.

11.4 Exporting your Personal Information.

If you would like to export your Personal Information, you will have to contact us by email at privacy@cintoo.com. We will send your exported data, free of charge within a reasonable time after receipt of your request.

11.5 Request that we stop using your Personal Information.

You may ask us to stop accessing, storing or using your Personal Information where you believe we don’t have the appropriate rights to do so. For such request, you may contact us by email at privacy@cintoo.com. We will investigate then respond to your request within a reasonable time.

12. California Online Privacy Protection Act

If you are a California resident, California law permits you to request information regarding the disclosure by Cintoo of your Personal Information to a third party for that third party’s direct marketing purposes. To make such request and opt out at any time after granting approval, please contact us by email to privacy@cintoo.com.

13. Children

The Website is not directed at children under the age of 18. We do not knowingly solicit or collect Personal Information from children under the age of 18.

14. Updates

If our Privacy Policy changes, we will post any changes on this page and if the changes are significant, we will post a notice on the Services homepages or will send you an email. We advise you to keep record of prior versions of this Privacy Policy. We also encourage you to review this Privacy Policy regularly to stay informed about our practices and the ways we can help you to protect your privacy. You will be bound by any changes to the Privacy Policy when you use the Services after such changes have been first posted.

15. Contact

If you have any questions or concerns about how your Personal Information is handled, please direct your inquiry to privacy@cintoo.com.